HUPC Comments On Noxious Weed Management EIS

Thanks much for your brief presentation on the Noxious Weed Management EIS at the October Wasatch National Forest breakfast meeting. We are in receipt of the scoping document and do have a couple of brief comments. Much of the document is meaningful and we commend you for that. On the other hand, we do have some notable.

Of course, we agree invasive/weed species are a deep concern and threat to inherent ecological diversity on the forest and action must be taken not only to control the individual, “satellite” or “established” populations of invasive plant species (the stated primary purpose of the scoping document), but it is even more important to focus on the processes of how these species have become so profoundly established and control those processes. It is here the data is replete with pleadings and warnings that it is only at this level that invasive plant establishment will be controlled.

Thus, as I suggested at the breakfast meeting, this EIS must truly be a science-based process/document. It is simply too easy to argue that the proposed action will rely on an Integrated Weed Management (IWM) strategy without clear documentation as to why choices are being made. We are fearful the scoping document has started down that path.

Many issues are identified throughout the text of the scoping document and noted very generally in the section entitled Preliminary Issues. Issues like impacts on water, fisheries, sensitive plants, endangered species, soils, buffer zones, etc. are noted in the document itself and then coalesced as a very broad statement in the scoping document’s Preliminary Issues: “…issues include potential effects of herbicides on the environment (including wildlife, fish and amphibians, and plant communities) and human health.” We trust the specific issues will be carried forward with the detail in the text of the scoping document and not simply languish as such a broad and meaningless impact upon the environment.

Other issues of note should focus on designated wilderness as well as wilderness recommended through the revised forest plan. Clearly invasive species threaten wilderness environments while at the same time the management actions prescribed by wilderness properly restrict the methods of control. In many ways wilderness and invasive species are foundational to the broad effort at controlling invasive species because of the realistic restrictions on management techniques and importance to the landscape (Asher and Harmon, 1995; USDA 2002; Marcus, et al, 1998; Anderson and Wotring, 2001). Clearly wilderness issues require a

broad, landscape approach not simply focused on wilderness. At the same time the wilderness forces us to focus on the issues as to whether the management actions specific to removing an infestation are worth the effort and don’t actually enhance the problem.

Notwithstanding the obvious and clear fact that roads are the primary reason for invasive species it is important this process deal with roads also in the context of management and control. Will additional access portals (roads or trails, temporary or not) be needed or considered in the particular management/control action? This becomes a crucial issue in analyzing the context of the fact that the cure may be worse or enhance the disease.

The primary problem with the scoping document/proposed action is that it, not surprisingly, focuses only on one tiny, and probably the least important, context of invasive plant management—isolating invasive plant populations and attempting to control or eradicate them independent of landscape management actions that enhanced the opportunity for invasive non-native species (With, 2002; Hobbs, et al., 1995; Conservation Biology, Special Section, Population Biology of Invasive Species, 2003).

We are hopeful that the Forest Service now recognizes what ecologists have recognized for decades that invasive species, plants and animals, represent a profound threat to functioning, integral ecosystem. The Forest Service has noted this threat is among the top four threats facing National Forest lands. Yet the response is too often, and likewise expressed in this scoping document/proposed action, a single faceted approach of ignoring management and landscape ecological based concerns and focusing only on isolated invasive plants/populations. This has merit only in the more important and second facet of altering anthropogenic activities that modify landscapes by either enhancing invasive plant dominance or allowing for the arrival of invasive plant species (see, for example, Kennedy, et al., 2002)

While the purpose and need for this action are clearly noted, the simple matter of fact is the scoping document, proposed action and subsequent Environmental Impact Statement must broaden the analysis from attacking populations to both attacking extant populations AND preventing the processes and conditions that allow for easy and broad access for invasive species. Among these are grazing, for example.

There is no dispute that one particularly insidious result of grazing on western ecosystems is the spread of exotic grasses and weeds (Jones 2000; Fleischner 1994; With, 2002; Hobbs, et al., 1995; Kennedy, et al., 2002). Ironically, biodiversity is recognized as a meaningful barrier to non-native plant invasion (Kennedy, et al., 2002) and grazing is one of the chief actions that alters and reduces native biodiversity at many levels. Weed infestations, then, of course, further reduce biodiversity (Kennedy, et al., 2002; Randall 1996).

Claims made in this scoping document/proposed action that some form of grazing can help prevent or minimize the spread of undesirable plant species must be shown to be scientifically credible (Kimball and Schiffman, 2003). Often the anecdotal explanations of grazing being used to remove some weedy species are based on observations within degraded systems with little chance of restoration (Jones 2000). Relying on one of the likely causes for weed species invasions to then remove them must be clearly supportable.

The literature is replete that roads, including primitive roads, are one of the most significant conduits for invasive plant species (Trombulak and Frissell 2000; Gelbard and Belnap, 2003; Forcella and Harvey 1983; Ercelawn, 1999; Davidson et al. 1996; DellaSalla and Strittholt et al. 1999, Parendes and Jones, 2000). Not at all surprising, much of this same research notes protection of roadless areas reduces the likelihood of exotic plant invasions and thus needs to be an integral discussion in exotic plant invasions.

Biological control is also noted in the scoping document as a potential agent to minimize invasive species. Within the last year a deep discussion has ensued over the efficacy of biological control (Hoodle, 2004; Louda and Stilling, 2004; Carruthers, 2004; Proffitt, 2004, Hoddle(a), 2004). Considerable doubt exists as to the long term safety of using biological agents to control invasive species and at the minimum biological control should undergo a scientific peer review process with very tight guidelines, protocol and clear expectations before being implemented.

The point is while the scoping document and proposed action offer one small facet of controlling exotic plant invasions, it is imperative that it be broadened to reflect a much deeper approach if, indeed, the intent is to control exotic plant invasions. For an issue that is considered so profoundly important, it seems exceedingly obvious this process recognizes a truly holistic (integrated) approach and should not be constrained to a singular approach.

DellaSala, Dominick and James Strittholt. Importance of Roadless Areas in Biodiversity Conservation: A Scientific Perspective. World Wildlife Fund and Conservation Biology Institute. December 1999.

Ercelawn, Ayesha. End of the Road. The Adverse Ecological Impacts of Roads and Logging: A Compilation of Independently Reviewed Research. Natural Resources Defense Council. December 1999.

Forcella, F. and S.J. Harvey. 1983. Eurasian Weed Infestation in Western Montana in relation to Vegetation and Disturbance. Madrono 30:102-109

Gelbard, Jonathan and Jayne Belnap. Roads as Conduits for Exotic Plant Invasions in a Semiarid Landscape. Conservation Biology. April 2003.

Hobbs, Richard. and Stella Humphries. An Integrated Approach to the Ecology and Management of Plant Invasions. Conservation Biology. August 1995.

Hoddle, Mark. Restoring Blance: Using Exotic Species to Control Invasive Exotic Species. Conservation Biology. February 2004.

Hoddle, Mark (a). The Strength of a Biological Control in the Battle against Invasive Pests: a Reply. Conservation Biology. February 2004.
Jones, A. L. 2000. Effects of Cattle grazing on North American Arid Ecosystems: A Quantitative Review. Western North American Naturalist 60: 155-164.

Parendes, Laurie and Julia Jones. Role of Light Availability and Dispersal in Exotic Plant Invasion along Roads and Streams in the H.J. Andrews Experiment Forest, Oregon. Conservation Biology. February 2000.

Proffitt, W. Trexkler. Legitimacy and Adoption of a Scientific Biological Control Program: an Institutional Analysis of Hoddle. Conservation Biology. February 2004